Alco, Inc., has a progressive board of directors and CEO who are committed to creating and maintaining an ethical culture within its business environment. It has an extensive corporate compliance and ethics program, a code of ethics, and regularly evaluates supervisors on monitoring good ethical standards in their division. Alco specifically prohibits the use of drugs and alcohol in the working environment. Harold, a top salesperson in the company, was discovered giving cocaine to buyers as an enticement to purchase Alco’s merchandise. He was reprimanded by the company but not discharged. The Justice Department is prosecuting Alco under a theory of vicarious liability, arguing the company has made thousands of dollars and benefited from Harold’s illegal behavior. Alco argues its compliance and ethics program and code of ethics prohibit giving gifts to procure a sales contract for any reason, and its “due diligence” is a defense to vicarious liability. Alco introduces as evidence its company’s efforts to develop and maintain an ethical corporate culture. Was Alco, Inc., acting ethically? Were they correct in their argument?